Republic of the Philippines

th
4 MUNICIPAL CIRCUIT TRIAL COURT
Second Judicial Region
Gonzaga-Sta. Teresita
Province of Cagayan

WILFREDO PASCUAL SR. Civil Case No.___________

Plaintiff,

Vs. -for-

MARK ANTHONY MANUEL “Forcible Entry with Damages”

AND THELMA MANUEL
Defendants.

x --------------------------------------------------x

JUDICIAL AFFIDAVIT
(LORETO AGRAMAN)

I, Loreto Agraman, Filipino citizen, of legal age, ________ and

a resident of Rebecca, Gonzaga, Cagayan, after having been sworn
to in accordance with the law do hereby depose and state that:

PRELIMINARY STATEMENT

Atty. Orlando B. Bareng Jr. is the lawyer who is questioning me

in this Judicial Affidavit. The interrogation is being conducted at his
Law Office located at Door 1, Marinez Building, National Highway,
Centro East, Sta. Teresita, Cagayan on September 17, 2020.

I am answering the questions fully conscious that I do so under

oath and that I may be held criminally liable for false testimony or
perjury.

PROFFER OF TESTIMONY

The testimony of the witness, Loreto Agraman, is offered to

prove the following:

1. Wilfredo Pascual Sr. is an owner of a parcel of land situated at

Barangay Rebecca, Gonzaga, Cagayan which is the subject
property in the instant case

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 2. Wilfredo Pascual is the possessor of the subject property prior
to the forcible entry of the defendants;

3. Mark Anthony Manuel and Thelma Manuel, by force and

intimidation, disturbed the peaceful possession of Wilfredo
Pascual Sr. and began constructing a concrete fence of the
subject property against the objection of the complainant;

4. Mark Anthony Manuel and Thelma Manuel refused to vacate

the subject property despite several demands from the plaintiff.

QUESTIONS (Q) AND ANSWERS (A)

QUESTION ANSWER
1. Mr. Witness, do you Yes sir.
know the plaintiff in this
case?

2. Why do you know He is my neighbor at Rebecca,

him? Gonzaga, Cagayan sir.

3. How about the
defendants, do you also
know them?
4. Are you familiar with
the real property subject
of this litigation?
Yes sir because they are also residents in
our barangay.
Yes sir because it is located near my
house.

5. Can you describe the It is a parcel of land situated at Rebecca,

subject property? Gonzaga, Cagayan Sir and owned by
plaintiff Wilfredo Pascual Sr.

6. Do you know the Yes sir. It is a portion of a property

history of the subject previously owned by Spouses Casimiro
property? and Petra Calizo which was sold to the
plaintiff Wilfredo Pascual Sr. who
immediately occupied it.

7. How do you know I know about it because I also bought a

about the history of the property from Spouses Casimiro and
subject property? Petra Calizo sir.

8. What is the It was previously an agricultural land sir,

classification of the but now it was already developed into a
subject property? residential area sir.

9. At the time that the The plaintiff sir, Wilfredo Pascual.

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subject property was still
an agricultural land, who
was cultivated the
same?

10. How can you say I am sure that it was the plaintiff who
that it was the plaintiff cutivated the property because I used to
who cultivated the work on the said property sir.
subject property?

11. Why did you work on The plaintiff Wilfredo Pascual hired me to
the subject property? plant rice on the property.

12. You said earlier that Wilfredo Pascual Sr. sir.

the subject property was
already developed into a
residential area, who
developed the same?

13. After the It was Wilfredo Pascual Sr. sir .

development of the
subject property, who
possessed and occupied
the same?

14. How can you say He constructed a bamboo fence on the

that it was Wilfredo subject property sir and he also caused
Pascual who possessed the construction of a deep well inside the
the subject property? property. In fact he had also undertaken
backfilling on the said property.

15. Is the bamboo fence Some part of the fence is still existing sir
still existing at this time? but other parts were already destroyed by
typhoons and others were removed by the
defendants.

16. How about the deep Yes sir. .

well, is it still existing?

17. At the present, who Thelma Manuel and Mark Anthony

is in possession of the Manuel sir.
property?

18. Why is it that it is Thelma Manuel and Mark Anthony

Thelma Manuel and Manuel forcibly entered the property with
Mark Anthony Manuel the aid of some men sir.
who are currently

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occupying the property, I
thought the property was
owned and possessed
by Wilfredo Pascual Jr.?

19. What happened after Wilfredo Pascual Sr. and his relatives
the entry of Thelma and reported the incident to the Office of the
Mark Anthony Manuel? Barangay Captain Sir.

20. After reporting the No sir.

incident, did Thelma
Manuel and Mark
Anthony Manuel vacate
the property?

21. What did Thelma They began the construction of a concrete

Manuel and Mark fence sir.
Anthony Manuel do after
forcibly entering the
property?

19. From the time that Wilfredo Pascual sir until forcibly taken by
the subject property was the herein defendants sometime on the
bought by the plaintiif up month of September sir.
to this year, who was in
possession of the same?
20. I have no further None sir.
questions. Do you have
anything to add or
retract?

IN WITNESS WHEREOF, I hereby affix my signature this

___________________________ in Tuguegarao City, Cagayan.

Loreto Agraman
Affiant

SUBSCRIBED AND SWORN to before me this

___________________ in Tuguegarao City, Cagayan. Affiant is
personally known to me.

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Doc No. ___
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Series of 2020

ATTESTATION

I, Atty. Orlando B. Bareng Jr., with office address at Door 1,

Martinez Building, Centro east. Sta. Teresita, Cagayan, under oath,
attests as follows;

I personally conducted the examination as witness of Fides

Rialubin in Civil Case ______________ pending at Municipal Trial
Circuit Trial Court for Gonzaga-Sta. Teresita, Cagayan; I faithfully
recorded the questions I asked and the corresponding answers that
the witness gave and that neither I nor any other person present or
assisting me has coached the witness regarding the latter’s
statement.                                               

ATTY. ORLANDO B. BARENG JR.

SUBSCRIBED AND SWORN to before me this

___________________ in _____________________. Affiant is
personally known to me.

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Book No. ___
Series of 2020